TRAA Opposing FMCSA Proposed Rulemaking Requiring Speed LimitersSpeed Limiting Devices [Docket No. FMCSA–2022–0004]. The proposal would require that "(CMVs) in interstate commerce with a gross vehicle weight rating (GVWR) or gross vehicle weight (GVW) of 11,794 kilograms or more (26,001 pounds or more), whichever is greater, that are equipped with an electronic engine control unit (ECU) capable of governing the maximum speed be required to limit the CMV to a speed to be determined by the rulemaking and to maintain that ECU setting for the service life of the vehicle." A speed has not been determined, but previous proposals mentioned rates of 60, 65 or 68 miles per hour.
TRAA understands the intention of FMCSA, NHTSA, and other groups to improve roadway safety and reduce roadside fatalities. However, TRAA opposes the proposal based on our belief that CMV speed limiters would in fact have the opposite effect. While there are several problems with the proposal, our primary concerns are the following:
- Increased Risk of Traffic Incidents: Speed limiters prevent operators from changing speeds as necessary to move with traffic flow. Variations in speed increase the rate of interactions between vehicles which in turn increases the rate of incidents. Operators must be able to slow down or speed up based on the traffic conditions, location, and environment to limit interactions with other vehicles.
- Increased Danger to Responders: Commercial vehicle operators must be able to move with the flow of traffic and change lanes as needed. Any efforts that prevent an operator's ability to do so increases the risk of death or injury to any responder or motorist along the roadside. Nothing should limit an operator's ability to Move Over.
TRAA has implemented a two-prong strategy for opposing this proposed rulemaking.
- Comment of Opposition: Firstly, we are in the process of submitting a comment of opposition on the official register. We are asking our affiliate state associations to sign-on and submit coordinated comments. Please email the office for more information.
- TRAA Joins Coalition: Secondly, TRAA is again joining forces with other organizations that are also in opposition to the proposal including OOIDA and others. While we don't agree on everything, we do agree that this proposal is bad news and TRAA's participation on similar coalitions for the insurance mandate, Dr. Weil's nomination, etc. have yielded the desired outcomes. We'll keep the membership posted on the coalition's progress.
As your voice on Capitol Hill, TRAA is proud to be advocating on behalf of the industry and our members. We appreciate the support of each and every member; we couldn't do this critical work without you!